ARTICLE 6
Nondiscrimination 1. A national of one of the Contracting States shall not be subject in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected. 2. The taxation on a permanent establishment which a national or corporation of one of the Contracting States has in the other Contracting State shall not be less favourably levied in that other Contracting State than the taxation levied on a national or corporation of that other Contracting State carrying on the same activities. This paragraph shall not be construed as obliging either Contracting State to grant to nationals of the other Contracting State any personal allowances or deductions which are by its law available only to residents of that former Contracting State. 3. A corporation of one of the Contracting States, the capital of which is wholly or partly owned by one or more nationals or corporations of the other Contracting State, shall not be subjected in the former Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar corporations of the former Contracting State the capital of which is wholly owned by one or more nationals or corporations of that former Contracting State are or may be subjected. 4. For the purposes of this Article, the present Convention sahll also apply to taxes of every kind and to those imposed at the national and local levels. ARTICLE 7
Business Profits 1. The industrial or commercial profits of a resident or corporation of one of the Contracting States shall not be subject to tax in the other Contracting State unless the resident or corporation carries on a trade or business in that other Contracting State through a permanent establishment situated therein. If it carries on a trade or business as aforesaid, industrial or commercial profits of that resident or corporation may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment. 2. Where a resident or corporation of one of the Contracting States carries on a trade or business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the industrial or commercial profits which it might be expected to make if it were a distinct and separate resident or corporation engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the resident or corporation of which it is a permanent establishment. 3. In the determination of the industrial or commercial profits of a permanent establishment, there shall be allowed as deduction expenses which are incurred for the purpose of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. 4. No profits shall be deemed to be derived from sources within the Contracting State in which a permanent establishment is located, merely by reason of the purchase of goods or merchandise by that permanent establishment, or by the resident or corporation of which it is a permanent establishment, for the account of that resident or corporation. 5. For the purposes of this Article, the term, "industrial or commercial profits" means income derived from the active conduct of a trade or business. It includes profits from manufacturing, mercantile, agricultrual, fishing, extractive activities, transportation or communication. It also includes income from banking, insurance and similar activities, but does not include income dealf with in Article 11 (Dividends), Article 12 (Interest), Article 13 (Royalties), Article 14 (Income from lmmovable Property), or Article 15 (Income from Personal Services). ARTICLE 8
Definition of Permanent Establishment 1. The term "permanent establishment" means a fixed place of business through which a resident or corporation of one of the Contracting States engages in trade of business. 2. The term "a fixed place of business" includes, but is not limited to. (a) an office; (b) a store or other sales outlet; (c) a workshop; (d) a factory; (e) a warehouse; (f) a mine, quarry or other place of extraction of natural resources; (g) a building site or construction, installation or assembly project which exists for more than six months. 3. Notwithstanding paragraph (1) of this Article a permanent establishment shall not include a fixed place of business used only for one or more of the following activities: (a) for the processing by another person of goods or merchandise belonging to the resident or corporation; (b) for the purchase of goods or merchandise for the account of the resident or corporation; (c) for the storage and/or delivery of goods belonging to the resident or corporation; (d) for the collection of information for the resident or corporation; (e) for advertising, the conduct of scientific research, the display of goods or merchandise, the supply of information or similar activities which have a preparatory or auxiliary character in the trade or business of the resident of corporation. 4. Even if a resident or corporation of one of the Contracting States does not have a permanent establishment in the other Contracting State under paragraph (1) - (3) of the this Article, nevertheless he shall be deemed to have a permanent establishment in the latter State if he engages in trade or business in that State through an agent who---- (i) has an authority to conclude contracts in the name of that resident or corporation and regularly exercises that authority in the latter State, unless the exercise of its authority is limited to the purchase of goods or merchandise for the account of the resident or corporation; or (ii) regularly secures orders in the latter State for that resident or corporation; or (iii) maintains in the latter State a stock of goods or merchandise belonging to that resident or corporation from which he regularly makes deliveries. 5. Notwithstanding paragraph (4) of this Article, a resident or corporation of one of the Contracting States shall not be deemed to have a permanent establishment in the other Contracting State merely because it uses the services in that State of a bona fide broker, general commission agent, forwarding agent, custodian or other agent of independent status acting in the ordinary course of its business. For this purpose, an agent shall not be considered to be an agent of independent status if it acts as an agent exclusively or almost exclusively for the resident or corporation (or for that resident or corporation and any other person controlling, controlled by, or under common control with that resident or corporation) and carries on any of the activities described in paragraph (4) of this Article. 6. The fact that a corporation, of one of the Contracting States controls or is controlled by (a) a corporation of the other Contracting State or (b) a corporation which engages in trade or business in that other Contracting State (whether through a permanent establishment of otherwise),shall not be taken into account in determining whether the activities or fixed place of business of either corporation constitutes a permanent establishment of the other corporation. 7. A resident or corporation of one of the Contracting States shall be deemed to have a permanent establishment in the other Contracting State if that resident or corporation provides the services in the latter State of public entertainers referred to in Article 15. ARTICLE 9
Ship and Aircraft 1. Notwithstanding the provisions of paragraph (1) of Article 7, income derived by a resident or corporation of one of the Contracting States from the operation of aircraft in international traffic shall be exempt from tax in the other Contracting State. 2. The tax imposed in one of the Contracting State according to the provisions of Article 7 on income derived by a resident or corporation of the other Contracting State from the operation of ships in international traffic shall be reduced by an amount equal to 50 per cent thereof. 3. The provisions of paragraph (1) and (2) of this Article shall likewise apply in respect of participations in a pool, in a joint business or in an international operations agency of any kind by a resident or corporation of one of the Contracting States engaged in the operation of ships or aircraft in international traffic. ARTICLE 10
Related Persons 1. Where a resident or corporation of one of the Contracting States deriving industrial or commercial profits in the other Contracting State and any other person are related and where such related persons make arrangements or impose conditions between themselves which are different from those which would be made between independent persons, then any income which would, but for those arrangements or conditions, have accrued to such resident or corporation but, by reason of those arrangements or conditions, has not so accrued, may be included in the income of such resident or corporation for the purposes of the present Convention and taxed by that other Contracting State accordingly. 2. (a) A person other than a corporation is related to a corporation if such person participates directly or indirectly in the management, control or capital of the corporation. (b) A corporation is related to another corporation if either participates directly or indirectly in the management, control, or capital of the other, or if any person or persons participate directly or indirectly in the management, control or capital of both corporations. | 
